Pension Consultants, Inc. is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) and is a corporation formed under the laws of the State of Missouri.
• The firm’s Founder, Chairman, and Chief Executive Officer is Brian Allen.
• The firm’s Chief Compliance Officer is Elizabeth Angus.
• Pension Consultants has been registered as an investment adviser with the SEC since October 1999. Prior to its registration with the SEC, Pension Consultants was registered as an investment adviser with the State of Missouri. Description of Primary Advisory Services Pension Consultants, Inc.’s (hereafter referred to as “PCI” or “we”) focus is on providing advisory services to retirement plan sponsors and to individual participants holding assets in retirement plans. Below are descriptions of our retirement plan services and our RetireAdvisers® Consulting Services. Retirement Plan Services The following are our retirement plan services: Clients are required to execute a services agreement for the provision of the selected retirement plan service(s). Below is a summary of our retirement plan service offering. Next to each service delivery named below is an indication of whether it falls into the category of Fiduciary Services or Non-Fiduciary Services for purposes of the Employee Retirement Security Act of 1974, as amended (“ERISA”); this categorization is described below under ERISA Disclosure. The service agreement provides additional details regarding the retirement plan services. PERFORMANCE-DRIVEN RETIREMENT PLAN MANAGEMENT The PERFORMANCE-DRIVEN RETIREMENT PLAN MANAGEMENT services provided include the following: 1) Investment Lineup Management (Fiduciary Services) – selecting and monitoring the investment line-up of the Plan 2) Fees Management (Fiduciary Services) – selecting and monitoring Plan vendors and fees 3) Contributions Management (Non-Fiduciary Services) – total contributions assessment and retirement guidance for Plan participants 4) Performance Reporting (Fiduciary Services) Below is a summary of each of our grandfathered retirement plan service offerings for clients that signed an advisory agreement prior to July 31, 2019. These services will continue to be available to those existing clients who were working with us prior to July 31, 2019. These grandfathered services are not available to new clients. Next to each service name below is an indication of whether the service falls into the category of Fiduciary Management, Fiduciary Consulting or Non-Fiduciary for purposes of ERISA; this categorization is described below under ERISA Disclosure. The service agreement provides additional details regarding the retirement plan services. A. PERFORMANCE-DRIVEN RETIREMENT PLAN MANAGEMENT The PERFORMANCE-DRIVEN RETIREMENT PLAN MANAGEMENT services provided for agreements effective dated prior to July 2019 include the following: 1) Investment Lineup Management (Fiduciary Services) – selecting and monitoring the investment line-up of the Plan 2) Fees Management (Fiduciary Services) – selecting and monitoring Plan vendors and fees 3) Optional Contributions Management (Non-Fiduciary Services) – retirement readiness assessment and retirement guidance for Plan participants 4) Performance Reporting (Fiduciary Services) B. 3(38) CORE COMPLETE (only available to grandfathered clients) The 3(38) CORE COMPLETE Services package includes the following: 1) Investment Management (Fiduciary Services) 2) Vendor Benchmarking (Non-Fiduciary Services) 3) Participant Education (Non-Fiduciary Services) 4) ERISA Supervision & Guidance (Non-Fiduciary Services) 5) Performance Reporting (Fiduciary Services) C. 3(21) CORE COMPLETE (only available to grandfathered clients) The 3(21) CORE COMPLETE Services package includes the following: 1) Investment Advisement (Fiduciary Services) 2) Vendor Benchmarking (Non-Fiduciary Services) 3) Participant Education (Non-Fiduciary Services) 4) ERISA Supervision & Guidance (Non-Fiduciary Services) 5) Performance Reporting (Fiduciary Services) D. 3(38) INVESTMENT COMPLETE (only available to grandfathered clients) The 3(38) INVESTMENT COMPLETE Services package is limited to the Investment Management services (Fiduciary Services), which are also available as a component service of the 3(38) CORE COMPLETE Services package. E. 3(21) INVESTMENT COMPLETE (only available to grandfathered clients) The 3(21)Investment COMPLETE Services package is limited to the Investment Advisement (Fiduciary Services) which are also available as a component service of the 3(21) CORE COMPLETE Services package. F. RETIREMENT PLAN AS NEEDED SERVICES (only available to grandfathered clients) The RETIREMENT PLAN AS NEEDED SERVICES package is for the provision of consultations from PCI in response to particular requests made by a client to address specific areas of concern identified by the client. RetireAdvisers® Consulting Services Our RetireAdvisers® Consulting Services include the following: Retirement COMPLETE Services RetireAdvisers® As Needed Services Clients are required to execute a services agreement for the provision of the selected RetireAdvisers® Consulting Service(s). The services agreement provides details regarding the service(s) to be provided. A summary description of the service offerings for the RetireAdvisers® Consulting Services is provided below. A. RETIREMENT COMPLETE SERVICES The Retirement COMPLETE Services include the following: 1) Investment Management 2) Retirement Planning Guidance The scope and frequency of the component services for the RetireAdvisers® Consulting Services package are based upon the client’s total portfolio value. B. RETIREADVISERS® AS NEEDED SERVICES RetireAdvisers® As Needed Services provide consultation when the client needs limited advisory services in reply to a particular area of concern. For the RetireAdvisers® As Needed Services, the client is responsible for identifying the specific areas of concern that the client would like PCI to address. Below is a summary of our grandfathered RetireAdvisers® Consulting Service offering for clients that signed a service agreement prior to December 31, 2023. These services will continue to be available to those existing clients who were working with us prior to December 31, 2023. These grandfathered services are not available to new clients. RETIREMENT COMPLETE SERVICES The Retirement COMPLETE Services include the following: 1) Investment Oversight 2) Retirement Planning Guidance The scope and frequency of the component services for the RetireAdvisers® Consulting Services package are based upon the client’s total portfolio value. ERISA Disclosure Services provided by PCI for retirement plans covered by ERISA will be identified as Fiduciary Services or Non-Fiduciary Services. Grandfathered services agreements note services are Fiduciary Management Services, Fiduciary Consulting Services or Non-Fiduciary Services in the Schedule(s). PCI will perform any Fiduciary

Services as a fiduciary, as defined in Section 3(21) of ERISA, act as the Investment Manager as defined by Section 3(38) of ERISA, and act in a limited capacity as the Administrator fiduciary as defined by Section 3(16) of ERISA. When providing Fiduciary Services, PCI’s services include discretionary authority to make investment and vendor decisions for the Plan. When acting as the Administrator Fiduciary as defined by Section 3(16) of ERISA, PCI’s role shall be limited to only the selection of the Plan’s record keeper. For services categorized as Fiduciary Consulting Services in grandfathered schedules, all recommendations of investment options and portfolios will be submitted to the client for the client’s ultimate approval or rejection. For Fiduciary Consulting Services, the retirement plan sponsor client or the plan participant who elects to implement any recommendations made by PCI is solely responsible for implementing all transactions. Fiduciary Consulting Services are not management services, and PCI does not serve as administrator or trustee of the retirement plan. PCI does not act as custodian for any client account or have authority to initiate third-party disbursements of client funds or securities with the exception of, for some accounts, having written authorization from the client to deduct our fees. PCI acknowledges that in performing Fiduciary Consulting Services for grandfathered schedules or otherwise providing investment advice related to assets of a retirement plan covered by ERISA, PCI is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of ERISA. PCI will act in a manner consistent with the requirements of a fiduciary under ERISA for all services for which PCI is considered a fiduciary under ERISA. If a retirement plan has elected to receive Fiduciary Consulting Services and not Fiduciary Management Services, PCI (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of Client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire, or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined by the Advisers Act, the retirement plan services that are identified as Non-Fiduciary should not be considered fiduciary services for the purposes of ERISA since PCI is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact suite of services provided to a client will be listed and detailed in the Services Agreement and accompanying Schedule (if applicable). To the extent required by ERISA Regulation Section 2550.408b-2(c), PCI will disclose any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which PCI is informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), PCI will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to a Services Agreement and any compensation or fees received in connection with that Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms, and schedules issued thereunder. If PCI makes an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), PCI will disclose to the client the correct information as soon as practicable, but no later than thirty (30) days from the date on which PCI learns of such error or omission. Newsletters PCI occasionally prepares general, educational, and informational newsletters. Newsletters are always offered on an impersonal basis and do not focus on the needs of a specific individual. Limits Advice to Certain Types of Investments PCI provides investment advice on the following types of investments:
• No-Load (i.e. no trading fee) and Load-Waived (i.e. trading fee waived) Mutual Fund Shares
• Exchange-listed securities (i.e. stocks)
• Securities traded over-the-counter (i.e. stocks)
• Fixed income securities (i.e. bonds)
• Closed-End Funds and Exchange Traded Funds (ETFs)
• Corporate debt securities (other than commercial paper)
• Certificates of deposit
• Municipal securities
• Variable annuities
• United States government securities PCI does not provide advice on foreign issues, warrants, commercial paper, options contracts on commodities, futures contracts on tangibles or intangibles, interests in partnerships investing in oil and gas interests, or hedge funds and other types of private (i.e. non-registered) securities. (Please refer to Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss for more information.) No Participation in Wrap Fee Programs A wrap fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions. In traditional management programs, advisory services are provided for a fee but transaction services are billed separately on a per-transaction basis. In wrap-fee programs, advisory services and transaction services are provided for in one fee. PCI does not act as a portfolio manager of or sponsor wrap fee programs. Tailor Advisory Services to Individual Needs of Clients PCI services are always provided based on the individual needs of each client. This means, for example, that clients are given the ability to impose restrictions on any accounts PCI advises on, including specific investment selections and sectors. PCI works with each client on a one-on-one basis through interviews and questionnaires to determine the client’s investment objectives and suitability information. Client Assets Managed by Pension Consultants As of December 31, 2023, Pension Consultants, Inc. has $1,944,022,623.18 of assets under management on a discretionary basis and $2,502,637,233.29 of assets under management on a non-discretionary basis for a total of $4,446,659,856.47.